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20 April 2018

Guideline for Producers and Importers on Banned “PAHs” Found in Consumer Goods Including Clothing, Footwear and Toys

The European Chemicals Agency (ECHA) published a guideline in March 2018 which is intended to assist producers, importers and distributors. The guideline concerns the restriction of polycyclic aromatic hydrocarbons (PAHs).

The placing on the market for supply to the general public of articles containing PAHs is restricted by Entry 50 of Annex XVII of the REACH Regulation. Hong Kong companies may recall that said Annex XVII sets out a “restriction” list of substances that are deemed too dangerous for inclusion in products placed on the EU market, and includes, as notable entries, phthalates in toys, azodyes in textiles and cadmium in plastics, among several others.

Entry 50 covers any articles that are placed on the market for supply to the general public. Such articles will infringe the restriction if any of their rubber or plastic components that come into direct as well as prolonged contact or short-term repetitive contact with human skin or the oral cavity, under normal or reasonably foreseeable conditions of use, contain more than 1 mg/kg (0.0001% by weight of this component) of any of the 8 PAHs that are identified in Column 1 of the Entry.

Entry 50 also includes a non-exhaustive list of types of articles falling within the scope of the restriction. As all these are commonly sold to customers in the EU from mainland China and Hong Kong, the restriction and the guideline should be of particular interest:

Sport equipment such as bicycles, golf clubs, racquets,

Household utensils, trolleys, walking frames,

Tools for domestic use,

Clothing, footwear, gloves and sportswear,

Watch-straps, wrist-bands, masks, head-bands.

It is furthermore noteworthy that the restriction entry also covers toys, including activity toys, and it covers childcare articles. These are covered in the same way but with a concentration limit of 0.5 mg/kg. The reason behind the lower concentration limit is that children – it is felt – may be more affected by exposure to PAHs.

PAHs may be present in articles produced from materials where mineral oil-based or coal-based extender/plasticiser oils have been used, or where carbon black has been used. PAHs in articles supplied to the general public may also originate from recycled rubber (e.g. recycled tyres) or plastic containing any of the aforementioned materials.

The materials in articles or components of articles most likely affected by this restriction are rubber surfaces and soft or dark plastic surfaces.

When assessing whether the rubber or plastic components of articles come into direct contact with human skin or the oral cavity, attention should be given to surfaces of the article (or parts of the article) that are touched or are in touch with the skin. ECHA acknowledges that it is not possible to develop an exhaustive list of all the articles that may fulfil the criterion of direct contact with human skin or the oral cavity. However, examples of articles which fall under this definition were developed by ECHA in collaboration with stakeholders and include masks, balloons, bracelets, handles, grips, hand tools, gloves and diving suits.

Moreover, prolonged contact is understood as an extended duration of contact, for example from carrying an article, sitting on it, leaning towards it, holding on to it, wearing it or keeping it in the mouth for an extended and uninterrupted length of time.

As for short-term repetitive contact with the human skin or the oral cavity, this is understood as brief acts of contact repeated several times over a relatively short period of time. Examples of such articles include frisbees, shuttlecocks, holding devices on domestic appliances (such as blenders or coffee machines), measuring tapes, the buttons on certain kinds of devices (such as handheld game consoles), balloons and thermos bottles.

On the other hand, the following are out of the restriction’s scope: plugs, cable sheathings (except on cables that are in long or repetitive contact with the skin, such as headphone cables, which are within the scope), bicycle tyres, and lamp or power switches. These are deemed to be in short and infrequent contact with the skin (as they are expected to be touched only once or twice per use).

The ECHA guideline provides several lists of articles that fall within the scope of the restriction, as well as images of some of these articles. For more information on the restriction and the in-scope product lists, please click on the following for the ECHA guideline.

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